Voya Financial Advisors Inc

Item 5             Fees and Compensation

In general, fees for VFA investment advisory services are based upon a percentage of assets under
management and are charged in advance by debiting advisory fees from client accounts, except as
otherwise specified below. VFA will prorate the fee it charges you if more than $10,000 is deposited or
withdrawn from your account during the billing period. Certain clients may have unique fee arrangements
that are not specified herein.

Fees that are specific to each VFA investment advisory program are described in detail in Item 5. Account
sizes specified for each program are negotiable under certain circumstances. VFA may group certain
related client accounts for the purposes of achieving the minimum account size and determining the
annualized fee.

Although VFA has established the fee schedules described in this Brochure, VFA’s IARs, with the
exception of its phone-based IARS, may negotiate alternative fees on a client-by-client basis. The fee
schedules contained in this Item 5, therefore, are the maximum amount, or ceiling, that VFA can charge.
Depending on the distribution channel of your IAR, you will receive higher or lower fees in any of VFA’s
investment advisory programs. Client facts, circumstances and needs are considered in determining the
fee schedule. These facts include the complexity of the client’s situation, assets to be placed under
management, anticipated future additional assets, related accounts, portfolio style and account
composition, among other factors. The specific annual fee schedule is identified in the contract between
the IAR and each client.

VFA’s phone service employee IARs (commonly referred to as the “Investor Channel”) may engage
prospective and current customers, including those Clients with existing VFA retail accounts or Voya
retirement plan participants who have separated from their employer-sponsored plan offered by our
affiliates, VRIAC and Voya Institutional Plan Services, LLC, to offer the opportunity to participate in the
Select Advantage Advisory Program or other affiliated programs or products. VFA does not pay the
Investor Channel IARs any portion of the investment advisory fee VFA earns. Rather, Investor Channel
IARs earn a salary and monthly incentive payouts based on individual performance factors, which differ
depending on the IAR’s role. These factors include achieving individual and department annual sales
goals, client engagement activity, client retention, and customer satisfaction. This compensation model
creates a conflict of interest, as Investor Channel IARs are incentivized to sell products and services, and
retain assets within their employer sponsored plan and rollover assets to VFA or an affiliate VFA and its
affiliates to increase their incentive compensation. The IAR is incentivized to make recommendations
based on the IARs performance factors, which creates a conflict of interest. VFA addresses this conflict
by disclosing it and through supervision of its phone service employee IARs which is designed to ensure
appropriateness of the advice and recommendations provided by its IARs.

VFA policies make certain financial products, such as illiquid non-traded products, available to clients only
in the Firm’s role as a broker-dealer, for which it receives commissions. Other registered investment
advisers may offer such financial products in an investment advisory account, shares of which may be
purchased net of commission, resulting in more shares to the customer than if the same product is
purchased through the Firm on a commission basis. Purchasing such products through the Firm in its role
as broker-dealer will result in the client receiving fewer shares for the same purchase price than the
customer would receive if purchased in an investment advisory account. Clients will receive lower
investment returns over the short term, and incur higher execution costs due to the Firm’s policy, as
compared to the same financial product held in an investment advisory account. In certain scenarios, a
client will pay more fees and expenses over the course of holding the product by purchasing it from VFA
in its capacity as a broker-dealer than the client would pay if the product had been purchased in an
investment advisory account. Since offering such financial products only in the Firm’s capacity as a
broker-dealer creates a conflict of interest, the Firm has an obligation to notify clients of, and to obtain
informed consent for, these types of recommendations at the time of sale. VFA does not owe clients a
fiduciary duty in circumstances when it offers clients products in its role as a broker-dealer.

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VFA policy makes certain share classes of products available on its investment advisory platform, as
opposed to other share classes of the same product. The share classes VFA makes available on its
investment advisory platform are selected, in part, because such share classes provide compensation to
the Firm. You are able to purchase the same or similar products that the Firm offers at other investment
advisers, and such investment advisers will make available lower cost share classes of those products to
you. For example, VFA does not offer retirement share, or “R Share” classes to non-retirement plan
customers, despite R Shares being less costly than the share classes VFA offers to investment advisory
customers. Other mutual fund share classes, such as “clean shares” are also available but not used by
VFA because such mutual fund share classes do not pay additional revenue to VFA. Such other share
classes are available to you through other investment firms, which would result in lower cost to you.
Similarly, investment advisory services fees charged by other investment advisers may be similar to or
lower than the fees that VFA charges.

Termination of the Advisory Relationship
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Item 7             Types of Clients

VFA provides investment advisory services to the following types of clients:

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    •    Individuals, including high net worth individuals
    •    Pension and profit sharing plans (and plan participants)
    •    Municipalities and other government entities
    •    Charitable organizations and other tax exempt enterprises
    •    Corporations, trusts, or other entities not listed above

Certain investment advisory programs offered through VFA are subject to account minimums. The
minimums applicable to each program are disclosed in Item 5 of this Brochure. IARs may choose not to
accept an investment advisory relationship due to the assets, or lack thereof, that the potential client is
proposing to invest with VFA.

Certain account types are only available through the Firm in certain investment advisory programs. The
Firm offers donor advised funds, but does so at this time only through the Firm’s Unified Managed
Account Program. This is a conflict of interest, as the Firm restricts donor advised funds to the Unified
Managed Account Program to support its own business model, instead of client preference. Donor
advised funds are available at other broker dealers and investment advisers for less cost.